German packaging law updates: less than a month to comply

Published: 11 December 2018 - Rachel Tucker

UK companies which sell goods to Germany have less than a month to comply with the country’s updated packaging laws or face fines of up to €200,000. Businesses could also be prohibited from selling goods on the German market if they fail to adhere to the new legislation.

All companies exporting goods to Germany must participate in a dual system to facilitate packaging recovery after use to continue trading in this market from the start of next year. Firms must register with the Central Authority before dispatching any products or the first time in Germany. This registration must be completed before 1st January 2019, with businesses required to provide their company name, address, contact details, identification and tax registration numbers and brand names.

Brands producing volumes of packaging higher than 80,000 kilos of glass, 50,000 kilos of paper and cardboard and 30,000 kilos of aluminium, plastics or tinplate in goods sold in Germany which fail to submit a declaration of completeness (DOC) could receive a €200,000 fine.

Germany has set targets to recover and recycle 90 per cent and 63 per cent of plastics and mechanically reclaimed materials respectively placed on the market by 1st January 2019 and 90 per cent of all metal, glass and paper by 2022. However, recent figures published by the Federal Environment Agency (UBA) showed that Germany consumed more than 220 kilos of packaging per capita in 2016, more than any other country in the EU.*

“The country’s pending VerpackG legislation will affect all manufacturers, importers, distributors and online retailers placing goods for sale on the German market,” said Michelle Carvell, COO of Lorax Compliance. “Packaging waste reduction will be even more on the country’s radar following the publication of these surprising UBA figures, with Germany keen to show it is taking action to shrink its environmental footprint.”

“It’s imperative that companies check their compliance requirements to maintain market access, as we have no doubt that the VerpackG legislation will be robustly enforced. The new reporting structure also requires companies to review their previous classifications of business to business and business to consumer packaging through 36 product groups, which is far more detailed than before. We urge any businesses which are uncertain about their environmental obligations to get in touch and to leave plenty of time to ensure their compliance in this market.”

Germany is the second largest exports destination for UK businesses, with £49 billion in goods and services sold into the country in 2016.**